Spomer v. Littleton

Background

Seventeen Black and two white residents of Cairo, Illinois, sued, saying the county State’s Attorney, Peyton Berbling, intentionally favored white people and refused to prosecute or properly handle crimes against Black residents. They described many specific incidents and asked a federal court to stop those practices, require monthly reports about complaints, and keep supervising the office. The District Court dismissed the request for an injunction; the Court of Appeals later allowed the possibility of injunctive relief if the plaintiffs could prove discrimination.

Reasoning

Before this Court decided the merits, a new State’s Attorney, W. C. Spomer, was elected and automatically substituted for Berbling. The Court examined the record and found no allegations charging Spomer with continuing the practices; Spomer never appeared in the lower courts and respondents never sought to enjoin him. Because there was no concrete dispute with the successor, the Court concluded it could not properly decide injunctive relief against Spomer on the present record. The Court vacated the Court of Appeals’ judgment and sent the case back for the appeals court to determine whether the dispute is now moot and whether the plaintiffs should be allowed to amend their complaint to name or allege facts about the new prosecutor.

Real world impact

The opinion does not resolve whether the original discrimination claims are true. Instead, it forces further procedure: the appeals court must decide mootness and whether plaintiffs can amend to pursue an injunction against the new prosecutor. Any final decision on the alleged racial practices will await further factual development and litigation.